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Harold W. FRALEY, Plaintiff-Appellant, v. SECRETARY OF HEALTH AND HUMAN SERVICES, Defendant-Appellee
Citations: 733 F.2d 437; 1984 U.S. App. LEXIS 22682; 5 Soc. Serv. Rev. 104Docket: 83-5320
Court: Court of Appeals for the Sixth Circuit; May 8, 1984; Federal Appellate Court
Harold W. Fraley appeals the termination of his social security disability benefits by the Secretary of Health and Human Services, which was upheld by the district court. The core issues on appeal involve the adequacy of the evidence supporting the Administrative Law Judge's (ALJ) conclusions that Fraley's impairment is no longer severe and that he unreasonably declined recommended back surgery. Fraley, who is 27 and has an eleventh-grade education, originally received disability benefits following a work-related back injury in October 1976. His benefits were terminated in December 1980 after a review of his condition. During his testimony, he described severe lower back pain radiating to his right hip and leg, limitations in bending, lifting, and prolonged sitting or walking on hard surfaces. He expressed fear of undergoing surgery, citing concerns about the lack of guaranteed improvement and potential worsening of his condition based on experiences shared by others. Medical evidence includes multiple evaluations: - Dr. Alvis Porter found Fraley unable to work due to his back injury. - Dr. Curwood Hunter identified a herniated intervertebral disc and indicated that surgery was necessary for recovery. - Dr. Phillip Tibbs diagnosed Fraley with chronic lumbar facet syndrome and did not recommend surgery. - Dr. Ben Wiltberger and Dr. Robert Lowe confirmed the presence of a herniated disc and recommended surgical intervention, with Lowe stating that Fraley would remain permanently disabled without it. The conflicting medical opinions reflect ongoing uncertainty about Fraley’s condition and the appropriateness of surgical intervention. The Administrative Law Judge (ALJ) concluded that the claimant no longer had a severe impairment, although he acknowledged a significant impairment that could potentially be remedied through surgery. The Appeals Council upheld the ALJ's decision, noting that while surgery was suggested, the claimant's failure to pursue it was not the main reason for the decision. The clinical evidence indicated that the claimant's disability ended in October 1980. The district court later found substantial evidence supporting the Secretary's decision, primarily based on the claimant's unjustified refusal to follow medical treatment. Upon review, it was determined that the record lacked substantial evidence to support the Secretary's finding of no severe impairment. Notably, medical assessments from Drs. Hunter, Wiltberger, and Lowe indicated the presence of a herniated disc, contradicting the ALJ's assertion that there was no ongoing incapacitating condition. Furthermore, the review found no substantial evidence that the claimant unjustifiably refused prescribed treatment. According to regulatory guidelines, a claimant must follow prescribed treatment that could restore work capability, but acceptable reasons for not doing so include risks associated with the treatment. Although a hemilaminectomy might improve the claimant's condition, there was insufficient evidence that it would enable the claimant to return to work, and the surgery was deemed a suggestion rather than a requirement. Consequently, the district court's judgment was reversed, and the case was remanded for the reinstatement of benefits.